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The Federal Trade Commission’s Proposed Rule for Auto Dealers from the Perspective of Auto Dealers and Auto Finance Companies, with Guests Paul Metrey…
The Federal Trade Commission’s Proposed Rule for Auto Dealers from the Perspective of Auto Dealers and Auto Finance Companies, with Guests Paul Metrey…
ratings:
Length:
58 minutes
Released:
Dec 29, 2022
Format:
Podcast episode
Description
The FTC’s proposal would impose a number of new substantive and disclosure requirements on auto dealers in connection with the car buying or leasing process. We first discuss NADA’s comment letter to the FTC on the proposal, including NADA’s concerns with the process used by the FTC to issue the proposal and with the proposal’s disclosure, recordkeeping, website posting, and other requirements. We then discuss the auto finance industry’s concerns with the proposal, including the risks arising from the FTC Holder Rule, the industry’s call for safe harbors, and other steps auto finance companies can take to mitigate risks in connection with ancillary products. We conclude with a discussion of the CFPB’s focus on ancillary products, including CFPB supervisory activity, potential areas of CFPB scrutiny, and the CFPB’s use of its authority to supervise auto finance companies to influence dealer behavior. John Culhane, a partner in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.
Released:
Dec 29, 2022
Format:
Podcast episode
Titles in the series (100)
A Look at the Joint Community Reinvestment Act Proposal Issued by the OCC, FDIC, and Federal Reserve Board, with Special Guest Kenneth Thomas, President of Community Development Fund Advisors, LLC: Dr. Thomas is widely-viewed as the nation’s leading CRA expert and has advised federal regulators on CRA reform. After reviewing CRA’s origins and purpose, we discuss how the new proposal differs from the OCC’s rescinded 2020 final CRA rule and... by Consumer Finance Monitor